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monetizations became less attractive and are no longer used by Enron. Today, Enronenters into prepaids . . . .CITI-B 00449879-880 (quoted in Exam. III, App. D at 35). Another Citigroup document states thatthe Yosemite IV prepay allowed “Enron to maintain the advantageous accounting and rating agencytreatment of these financings” (quoted in Exam. III, App. D at 71). Citigroup clearly recognized thatthe rating agencies had focused on the discontinuity between Enron’s net income and funds flowand, accordingly, collaborated with the Insiders by providing prepay transactions to close the gapbetween the two. Citigroup gave the Insiders substantial assistance which furthered the Insiders’scheme to manipulate Enron’s financial statements. In doing so, Citigroup had full knowledge:• that the Citigroup prepays were loans disguised to look like commoditytrades,• that their purpose was to allow the Insiders to improperly account for theprepaid amounts as cash flow from operations and the obligation to repay theprepaid amounts as price risk management liabilities,• that in fact the Insiders were improperly accounting for the Citigroupprepays, and• that the Insiders were using the prepays to misstate Enron’s financialcondition and to mislead the rating agencies and others into believing thatEnron’s financial condition was better than it was.298. Citibank loaned its own funds to Enron in five of the prepay transactions. Citigroupassisted the Insiders in raising the funds for the Yosemite prepays by designing the credit-linkednote structure. With respect to the Yosemite I and II prepays, Citigroup also facilitated the purchaseof 50% of the equity in the trust that issued the credit-linked notes. Citigroup allowed its SPE Deltato serve as the pass-through party in eight of the prepays, and Citibank itself served as the passthroughin two other prepays. In addition, Citigroup caused Delta to make false representations toArthur Andersen, without which the accounting for the prepay transactions would not have beenpossible.604041v1/007457-93-